New Surveyor guidance increases PBJ oversight

REVISED: Revised Long-Term Care (LTC) Surveyor Guidance: Significant revisions to enhance quality and oversight of the LTC survey process

Memorandum Summary: Revised Surveyor Guidance: CMS is releasing the following revised guidance for nursing home surveyors: Admission, Transfer & Discharge, Chemical Restraints/Unnecessary Psychotropic Medication, Resident Assessment, Nursing Services, Payroll Based Journal, Quality of Life and Quality of Care, Administration, Quality Assurance Performance Improvement (QAPI), Infection Prevention and Control, and other areas. Added revised guidance and training for Nursing Services and Payroll Based Journal to the updates for Appendix PP and the Long-Term Care Survey Process and revised the effective date of implementation for all new guidance to April 28, 2025.

Centers for Medicare & Medicaid Services. “REVISED: Revised Long-Term Care (LTC) Surveyor Guidance: Significant revisions to enhance quality and oversight of the LTC survey process.” CMS.gov, 10 March 2025. https://www.cms.gov/medicare/health-safety-standards/quality-safety-oversight-general-information/policy-memos/policy-memos-states-and-cms-locations/revised-revised-long-term-care-ltc-surveyor-guidance-significant-revisions-enhance-quality-and-0

Quality, Safety and Oversight Letter 25-14-NH
Quality, Safety and Oversight Letter 25-07-NH
(expired, refer to QSO-25-14-NH)

CMS kicking survey enforcement into higher gear, experts caution

“There are penalties not just on survey for not submitting your PBJ data but there’s penalties in your Five Star. Everything is connected to each other. That’s another pandemic catch-up.” Since April, surveyors are better trained to examine and cite for insufficient data entry, or numbers that are too low — and they are sometimes making decisions before ever setting foot on campus.

— McKnight’s Long-Term Care News, August 13, 2025

Why CMS’s New LTC Guidance is a Blueprint for Transformation

CMS is signaling a future that demands more transparency, more precision, and above all, more humanity in the care we provide. The revised guidelines touch nearly every aspect of nursing home operations from staffing and infection control, to discharge procedures and Quality Assurance Performance Improvement (QAPI).

— Senior Living News, June 27, 2025

New nursing home surveyor guidance to finally go into effect Monday

CMS had already made guidance training for nursing home surveyors and providers publicly available in the Quality, Safety, and Education Portal. That included more information on how surveyors should use nurse staffing data collected from Payroll Based Journal files to determine possible concerns before an on-site inspection begins.

— McKnight’s Long-Term Care News, April 25, 2025

‘Airtight Documentation’ Matters: Inside Upcoming Nursing Home Survey Changes Taking Effect April 28

“The surveyors will now be doing a lot of off site preparation. They’re already doing quite a bit, but they’re going to be doing more off site preparation for your recertification survey. They’re going to be obtaining your PBJ staffing data report and evaluate it before they set foot in your facility. So they’re going to sort of be armed and ready, if you will, when they come in the door related to your PBJ.” Other changes include added F tags to the Payroll-Based Journal (PBJ) related to nursing services, registered nurse coverage and mandatory submission of PBJ data.

— Skilled Nursing News, April 22, 2025

Preparing For Change: New CMS Survey Guidance Effective March 24, 2025 (Video)

CMS has implemented significant revisions to its long-term care survey guidelines. The changes address a wide range of areas including admission agreements, medication management, infection control, payroll-based journal reporting, health equity, transfer and discharge processes, and MDS coding.

— Mondaq, February 20, 2025

CMS Revises Surveyor Guidance Again, Delays Implementation to March 2025

CMS’ newly revised guidance includes updates to FTag727:

Sufficient Nursing Staff, RN 8 Hrs./7days/Wk., Full Time DON, & Payroll-Based Journal: Guidance for investigations using the Payroll-Based Journal Staffing Data Report has been added. This report will be used as one of the sources of information indicative of potential noncompliance. Instructions specific to staff interviews, observations, key elements of noncompliance, and deficiency categorization are also added to the guidance. Instructions to surveyors based on whether or not the report identified concerns were added to the guidance. Investigative probes for the director of nursing (DON) requirements and deficiency categorization examples, as well as investigative procedures for evaluating compliance with the submission of direct care staffing information and payroll using the Payroll-Based Journal Staffing Data Report, were added to the guidance.

— PALTmed, January 17, 2025

CMS’ Latest Guidance Plagued by Lack of Clarity on Infection Prevention and Staffing, Leading to Concerns of Unfair Survey Citations

The current updates focus on the use of antipsychotics, nurse staffing, Payroll-Based Journal reporting and involuntary discharges. Priority tier schedules for surveys, revised facility assessment guidance, enhanced barrier precautions, risk-based surveys and the $75 million national staffing campaign were also outlined in the CMS document.

— Skilled Nursing News, January 15, 2025

CMS locks in 2025 nursing home surveyor priorities

Enforcement priorities include examining the use of antipsychotics, involuntary discharges, nurse staffing and Payroll-Based Journal reporting.

Although not new or surprising, the heightened focus on the management of antipsychotics is worth highlighting. CMS said it will continue to crack down on the inappropriate use of antipsychotic medications, which too frequently are prescribed through misdiagnoses, officials said.

— McKnight’s Long-Term Care News, January 15, 2025